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Santander Subject Access Request - My experience


parity4all
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Made a subject access request to Santander. One of the acknowledgement letters they sent says this (in bold):

 

Please note that some documents, such as company internal policies and procedures, promotional materials, terms and conditions etc contain no personal data and therefore do not fall under the remit of subject access request.

 

If anyone here has made a subject access request to Santander, can you please check the Acknowlegement letters to see if it says the same. If it appears can you include a scanned copy of the letter on this forum.

 

The ICO has told me:

 

Santander may provide such information as a standard paragraph as it is simply a means of reminding people that such information does not fall within the scope of a SAR.

 

Santander acknowledgment letter also says this about call recordings:

many of our customer contact numbers are taped for monitoring and training purposes only, by the telephone advisors individual log in and not by a customers name or account number. These records may be time limited. Where located, calls will be provided either as typed transcripts or data on a CD-ROM; please contact us if you anticipate any difficulties with this. Where no calls are available we will provide you with accompanying notes.

 

Santander did send me call recordings, but one of the recordings had a bit missing from the dialog. I've reported it to the ICO. They've just got back to me after 2 months and said I need to ask Santander for the missing data. I'll probably do that, and let everyone know if Santander does locate the "missing data".

 

BTW, about storing call recordings under telephone advisor's login (and not by customer name or account number). I'm pretty sure the Data Protection Law says if a living individual can be identified from the data, then it's classed as personal data. Here's the quote from the ICO website:

 

It is important to note that, where the ability to identify an individual depends partly on the data held and partly on other information (not necessarily data), the data held will still be “personal data”.
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You're quite right that if there are any references to the customer ID et cetera and these are accessible by means of a search, then they fall to be disclosed under the DPA.

 

Don't expect any kind of enthusiastic response from the information Commissioner. He wants a quiet life.

 

It's not surprising there are bits missing. Don't expect too much enthusiasm from Santander or any other institution about finding missing data for you.

 

Of course, you didn't really need these recordings did you, because you have been here since 2009 and so you know that you should be recording your own calls every time. Don't you.

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Of course, you didn't really need these recordings did you, because you have been here since 2009 and so you know that you should be recording your own calls every time. Don't you.

 

I've subscribed to the CAG email newsletter since 2010, and always made it a point to read it. Must have missed the "warning" (in small print, mind you) on the right hand side of it each time or not quite understood "creditors" to mean all "banks" (even if you are dealing with the bank not on the basis of a loan, mortgage account etc.).

 

On the other hand, the 'Big Inflation coming' warning has got across more than sufficiently, and that only became newsworthy recently.

 

For anyone interested in recording calls. Here are some CAG posts I found interesting:

 

http://www.consumeractiongroup.co.uk/forum/showthread.php?439552-Guidance-note-Dealing-with-Customer-Service-Departments-or-making-telephone-contracts&highlight=record+telephone+call

 

http://www.consumeractiongroup.co.uk/forum/content.php?34-Can-I-legally-record-telephone-calls

 

http://www.consumeractiongroup.co.uk/forum/content.php?380-Telephone-Call-Recording

 

Or you can search the CAG forums for keywords: "record telephone call"

 

and a bunch of results come up.

Edited by parity4all
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